Protocol

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....shall be an integral part of the Agreement: I. Ad. Article 5  In respect of sub-paragraph (a) of paragraph 3 of Article 5, it is clarified that for the purposes of computing the time limits referred to in this paragraph, the activities carried on by an enterprise associated with another enterprise within the meaning of Article 9 shall be aggregated with the period during which the activ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ales have been carried out for reasons other than obtaining a benefit under this Agreement. III. Ad. Article 8  In respect of Article 8, if the place of effective management of a shipping enterprise is aboard a ship, then it shall be deemed to be situated in the Contracting State in which the home harbour of the ship is situated, or, if there is no such home harbour, in t....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Article 12, it is clarified that the term "royalties" as used in this Article would be deemed to include payments of any kind received as a consideration for: (a) the reception of, or the right to receive, visual images or sounds, or both, for the purpose of transmission by: (i) satellite; (ii) cable, optic fibre or similar technology; or (b) the ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....imes) and back to back loans, whether existing on the date of entry of force of this Agreement or enacted subsequently. VII. It is understood that for Mexican tax purposes, the fixed base will be treated in accordance with the principles that apply to permanent establishment. IN WITNESS WHEREOF the undersigned, duly authorized thereto, have signed this Protocol. DONE in duplicate at&....